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# European Product Act (EPA) – Proposal for a New Framework Aligning Product Legislation with the Digital Era
- URL: https://atlas.tilkal.com/european-product-act-epa-proposal-for-a-new-framework-aligning-product-legislation-with-the-digital-era/
- Published: 2026-05-13T14:22:07.000Z
- Updated: 2026-07-13T08:02:57.000Z
- Description: Tilkal - The European Product Act (EPA) is a proposed legislative package resulting from the revision of the New Legislative Framework (NLF).
- Author: Tilkal
- Tags: Europe, Digital Product Passport, Circular Economy, Environment, Apparel & Fashion, Construction, Furniture & Home decoration, Food & Beverages, Mining & Minerals, Industry & Manufacturing, Plastics, Cosmetics, Social Responsibility, Toy Safety

\[Updated May 13, 2026\]

> **What.** *The *European Product Act (EPA)* is a proposed legislative package resulting from the revision of the *New Legislative Framework (NLF)*. It aims to modernize EU product legislation by integrating digital tools, circular economy principles, and enhanced market surveillance to strengthen the Single Market in the digital age.*

> **When.** *Expected adoption by the European Commission in the third quarter of 2026, following parallel revisions of the *Standardization Regulation (EU 1025/2012), New Legislative Framework Regulation, and Market Surveillance Regulation.**

> **Products.** *All products placed on the EU market, with a focus on harmonizing digital requirements, circularity, and compliance across sectors, including electronics, toys, construction, textiles, and consumer goods.*

> **Who.** *Manufacturers, importers, distributors, online marketplaces, and economic operators placing products on the EU market.* 

---

## Context: The New Legislative Framework (NLF) and Its Revision

The **New Legislative Framework (NLF)**, adopted in 2008, serves as the foundation for EU product legislation, including directives and regulations such as the **CE marking**, **conformity assessment procedures**, and **market surveillance rules**. The NLF was designed to:

- Improve the functioning of the **Single Market for goods**.
- Strengthen **market surveillance** to ensure product safety and compliance.
- Clarify the use of **CE marking** and harmonize conformity assessment processes.
- Provide a **toolbox of measures** for sector-specific product legislation.

However, the NLF was developed before the rise of **e-commerce, digitalization, and circular economy principles**, creating gaps in addressing modern challenges such as:

- The proliferation of **online marketplaces** and their role in product compliance.
- The need for **digital tools** (e.g., Digital Product Passports) to enhance traceability and transparency.
- The integration of **sustainability and circularity** into product design and lifecycle management.

The **revision of the NLF** is part of a broader effort to align EU product legislation with the **European Green Deal**, **Circular Economy Action Plan**, and **Digital Decade Policy Programme**. The **European Product Act (EPA)** will emerge from this revision, alongside updates to the **Standardization Regulation** and **Market Surveillance Regulation**, forming a cohesive legislative package.

## Objectives of the European Product Act (EPA)

The EPA aims to **reframe Single Market access** by addressing key challenges in the digital and circular economy. Its primary objectives include:

### 1\. **Digital Transformation of Product Legislation**

- Introduce **digital compliance tools**, such as [**Digital Product Passports**](https://atlas.tilkal.com/eu-digital-product-passport-dpp/) **(DPP)**, to standardize and streamline product information.
- Replace fragmented data carriers (e.g., multiple QR codes, labels) with a **single EU QR code** covering all regulatory requirements.
- Enhance **traceability and transparency** across supply chains, supporting circular economy practices.

### 2\. **Strengthening the Circular Economy**

- Integrate **circularity principles** into product design, including **durability, reparability, and recyclability**.
- Mandate **sustainability information** in product documentation, such as material composition, carbon footprint, and end-of-life instructions.
- Align with the [**Ecodesign for Sustainable Products Regulation (ESPR)** ](https://atlas.tilkal.com/ecodesign-for-sustainable-products-regulation-espr-2/)and other sector-specific legislation (e.g., [**Construction Products Regulation (CPR) 2024/3110**](https://atlas.tilkal.com/eu-construction-products-regulation-cpr-2024-3110/), [**Batteries Regulation**](https://atlas.tilkal.com/eu-battery-regulation-2/)).

### 3\. **Enhancing Market Surveillance and Enforcement**

- Establish a **dedicated EU-level market surveillance authority** to coordinate cross-border enforcement and address non-compliance in e-commerce.
- Recognize **online marketplaces as economic operators**, making them **co-liable** for non-compliant products sold on their platforms.
- Improve **cooperation between national authorities** to ensure consistent enforcement across the EU.

### 4\. **Simplifying Compliance for Businesses**

- Reduce administrative burdens by **harmonizing digital requirements** and standardizing compliance documentation.
- Support **innovation and competitiveness** by providing clear rules for emerging technologies and business models.
- Foster **trust in the Single Market** by ensuring high safety, sustainability, and quality standards for all products.

## Key Proposals Under the European Product Act

The EPA is expected to introduce several transformative measures to modernize EU product legislation:

### 1\. **Single EU QR Code**

- Replace multiple data carriers (e.g., separate QR codes for CE marking, DPP, and other requirements) with a **single, standardized EU QR code**.
- The QR code will link to a **centralized digital platform** containing all regulatory information, including:**CE marking and Declaration of Performance (DoP)**.**Digital Product Passport (DPP)** data (e.g., material composition, sustainability metrics).**Market surveillance and compliance documentation**.

### 2\. **Digital Product Passport (DPP) Integration**

- The EPA will **formalize the role of DPPs** as a tool for **material traceability, transparency, and circularity** across all product sectors.
- DPPs will become a **mandatory requirement** for products placed on the EU market, building on sector-specific implementations (e.g., **CPR 2024/3110 for construction products**, **Batteries Regulation**).
- The EPA will define **standardized data fields** for DPPs, ensuring consistency and interoperability across sectors.

### 3\. **Online Marketplaces as Economic Operators**

- Online marketplaces (e.g., Amazon, eBay) will be **recognized as economic operators** under the EPA, making them **co-liable** for non-compliant products sold on their platforms.
- Marketplaces will be required to:Verify the **compliance of products** before listing them.Remove **non-compliant products** from their platforms upon notification by authorities.Cooperate with **market surveillance authorities** to ensure enforcement.

### 4\. **EU-Level Market Surveillance Authority**

- A **new EU-level authority** will be established to:Coordinate **cross-border market surveillance** and enforcement actions.Address **non-compliance in e-commerce**, where products often bypass traditional regulatory checks.Support **national authorities** in conducting inspections, testing, and product recalls.

### 5\. **Alignment with International Standards**

- The EPA will align with **international standards** (e.g., ISO, IEC) to ensure global interoperability and reduce barriers to trade.
- **CEN and CENELEC**, the European standardization organizations, will play a key role in developing **harmonized standards** for digital tools, circularity, and compliance.

## Link to Digital Product Passports (DPPs)

The **Digital Product Passport (DPP)** is a central pillar of the EPA, serving as a **digital tool for transparency, traceability, and circularity**. The EPA will build on existing sector-specific DPP implementations (e.g., **CPR 2024/3110, Batteries Regulation, ESPR**) to create a **unified framework** for all products placed on the EU market.

### **Role of DPPs in the EPA**

- **Standardization**: The EPA will define **mandatory data fields** for DPPs, ensuring consistency across sectors. This includes:**Product identification** (e.g., unique identifier, manufacturer details).**Sustainability information** (e.g., carbon footprint, recyclability, material composition).**Compliance documentation** (e.g., CE marking, test reports, certificates).**Lifecycle data** (e.g., repair instructions, end-of-life management).
- **Interoperability**: DPPs will be **machine-readable** and linked to the **single EU QR code**, enabling seamless access to product information for regulators, businesses, and consumers.
- **Circular Economy Support**: DPPs will facilitate **reuse, recycling, and material recovery** by providing stakeholders with detailed information on product composition and end-of-life options.
- **Market Surveillance**: DPPs will enhance **traceability** and enable authorities to quickly identify non-compliant products, reducing the risk of counterfeit or unsafe goods entering the market.

### **Synergies with Existing Regulations**

The EPA will **complement and reinforce** sector-specific DPP requirements, such as:

- **Construction Products Regulation (CPR) 2024/3110**: DPPs for construction materials, including sustainability and performance data.
- **Batteries Regulation**: DPPs for batteries, covering material sourcing, carbon footprint, and recycling information.
- **Ecodesign for Sustainable Products Regulation (ESPR)**: DPPs for a wide range of consumer products, focusing on durability, reparability, and circularity.

By standardizing DPPs across sectors, the EPA will **reduce fragmentation** and create a **cohesive digital ecosystem** for product compliance and sustainability.

## What’s at Stake for Businesses and Stakeholders?

The EPA represents a **paradigm shift** in EU product legislation, with significant implications for businesses, regulators, and consumers:

### **For Businesses**

- **Compliance Costs**: Companies will need to invest in **digital tools** (e.g., DPPs, QR codes) and **supply chain transparency** to meet new requirements.
- **Market Access**: Non-compliance with the EPA could result in **product bans, fines, or reputational damage**, particularly for companies selling through online marketplaces.
- **Opportunities for Innovation**: The EPA will create opportunities for businesses to **differentiate themselves** through sustainable and circular product design.
- **Supply Chain Resilience**: Enhanced traceability and transparency will help businesses **identify risks** (e.g., forced labour, hazardous materials) and improve resilience.

### **For Online Marketplaces**

- **Increased Liability**: Marketplaces will be **co-liable** for non-compliant products, requiring robust **compliance verification processes**.
- **Operational Changes**: Marketplaces will need to **integrate digital tools** (e.g., DPPs, QR codes) into their platforms and cooperate with authorities.

### **For Regulators and Authorities**

- **Enhanced Enforcement**: The EPA will provide regulators with **new tools** (e.g., DPPs, EU-level authority) to combat non-compliance and protect consumers.
- **Cross-Border Cooperation**: The proposed **EU-level market surveillance authority** will improve coordination between national authorities, reducing fragmentation.

### **For Consumers**

- **Greater Transparency**: Consumers will have **easy access to product information** (e.g., sustainability, safety, compliance) via DPPs and QR codes.
- **Improved Safety and Sustainability**: The EPA will ensure that products placed on the EU market meet **high standards** for safety, circularity, and environmental performance.

### **For the Single Market**

- **Reduced Fragmentation**: The EPA will **harmonize digital requirements** and compliance processes, reducing barriers to trade within the EU.
- **Global Competitiveness**: By aligning with **international standards** and promoting innovation, the EPA will enhance the EU’s **global leadership** in sustainable and digital product regulation.

## Next Steps and Timeline

The EPA is part of a **broader legislative package** that includes revisions to the **Standardization Regulation** and **Market Surveillance Regulation**. The timeline for adoption and implementation is as follows:

- **2024–2025**: **Public consultation and impact assessment** by the European Commission.
- **Q3 2026**: **Expected adoption** of the EPA by the European Commission.
- **2026–2027**: **Legislative process** in the European Parliament and Council.
- **2027–2028**: **Entry into force** and **phased implementation** of the EPA, including DPP requirements.
- **2028 onwards**: **Full applicability** of the EPA, with ongoing reviews and updates based on feedback.

Businesses and stakeholders are encouraged to **engage in the consultation process** and prepare for the transition by:

- Assessing **current compliance processes** and identifying gaps.
- Investing in **digital tools** (e.g., DPPs, QR codes) and **supply chain transparency**.
- Monitoring **developments in standardization** (e.g., CEN/CENELEC) and sector-specific regulations.

## For More Information

For further details on the **European Product Act (EPA)** and its implications, consult the following resources:

- [European Commission - New Legislative Framework (NLF) Revision](https://single-market-economy.ec.europa.eu/sectors/product-safety-and-compliance/new-legislative-framework%5Fen?ref=atlas.tilkal.com)
- [European Commission - Circular Economy Action Plan](https://environment.ec.europa.eu/strategy/circular-economy-action-plan%5Fen?ref=atlas.tilkal.com)
- [European Commission - Digital Product Passport](https://single-market-economy.ec.europa.eu/sectors/digital-product-passport%5Fen?ref=atlas.tilkal.com)
- [CEN and CENELEC - Standardization and the EPA](https://www.cencenelec.eu/?ref=atlas.tilkal.com)
- [USB-LAB - EU Product Law 2026: Digital Product Passports Transforming the Market](https://en.usb-lab.com/eu-product-law-2026-on-work-program-digital-product-passports-transforming-the-whole-market/?ref=atlas.tilkal.com)